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Tax controversy and litigation

Eversheds Sutherland’s tax controversy and litigation team offers a comprehensive multi-disciplinary service to help chart your way through complex disputes and anticipated future problems. If you are encountering the challenges of dispute resolution for the first time, our extensive knowledge allows us to deliver forward-thinking, individually tailored guidance on tax and the litigation process.

Experienced tax controversy and litigation lawyers

The experience of our international network of lawyers covers the whole spectrum of tax issues including corporate, partnership, individual and tax-exempt matters. Our team can advise you on how to deal with revenue authorities at every level, from tax audits and appeals to voluntary disclosure proceedings. Should a tax authority be unable or unwilling to reach an appropriate administrative resolution, we have a strong track record of litigating in court. In recent years, we have filed more than 100 court cases on behalf of more than 50 clients.

Our experience includes:

  • winning a case of first impression involving tax characterization of residual value insurance, resulting in the elimination of the asserted deficiency, which was more than $50 million
  • successfully arguing and winning an appeal in U.S. federal court regarding the statute of limitations for assessment in partnership cases
  • ongoing representation of an international insurance company in tax litigation regarding a $306 million tax refund
  • acting before the UK tax courts and higher courts including the Court of Appeal and Supreme Court as well as the Court of Justice of the EU, in relation to VAT, and direct taxes
  • a UK judicial review of HMRC’s decision for a major financial institution
  • dealing with a lead case on VAT grouping before the UK tax courts and on appeal
  • acting for a UK retailer in relation to a complex VAT issue, involving numerous witnesses and expert evidence
  • ongoing representation in front of the Italian tax courts of a UK insurance company in a tax litigation regarding a €18 million tax refund, with a positive outcome in first and second degree
  • acting for the Italian subsidiary of a Swiss company in relation to a tax litigation regarding, among others, alleged inventory differences and management fees
  • acting for German clients on VAT refunds and qualification of supplies to foreign customers as VAT-exempt
  • frequently representing German clients in tax audits and objection proceedings with tax authorities
  • representing Emperia Holding before the Polish Supreme Administrative Court. The case related to assuring for a Polish holding company tax deductibility of arbitration costs arising in an arbitration case relating to a share sale transaction
  • representing Orange Polska in tax litigation in a cash-pool case

Our specialization in this area is why one client was quoted in Chambers USA 2016, saying that our attorneys “get right to the heart of the issue, and their response is exactly what we need.” In the UK, the Legal 500 refers to the “excellent, client-focused team,” headed by Giles Salmond. Meanwhile, in Italy the Legal 500 says that our lawyers are “recommended for transfer-pricing issues and tax litigation over cross-border transactions,” and that “Rome-based Marco Melisse and Sebastiano Sciliberto are names to note.”

Contact our tax controversy and litigation team

If you would like any further information or need advice on tax controversy and litigation, please contact our legal team.

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